PRIVACY POLICY
ASOCIACIÓN DESARROLLO TECNOLÓGICO RURAL
Website: https://movimientotecnologicorural.org/
Last updated: 10 November 2026
1. INTRODUCTION
ASOCIACIÓN DESARROLLO TECNOLÓGICO RURAL (hereinafter referred to as “the Association”) is committed to protecting the privacy and personal data of individuals who visit its website, use its digital services, participate in its activities and projects, or maintain a relationship with the organisation.
This Privacy Policy provides information about the processing of personal data in connection with the corporate website, its forms, registration systems, electronic communications, and virtual tours developed using 3DVista Virtual Tour Pro.
Personal data is processed in accordance with:
- Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR).
- Spanish Organic Law 3/2018 on Personal Data Protection and the Guarantee of Digital Rights (LOPDGDD).
- Spanish Law 34/2002 on Information Society Services and Electronic Commerce (LSSI-CE).
- Any other applicable provisions concerning privacy and data protection.
The Association applies the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality and accountability.
2. DATA CONTROLLER
Data controller: ASOCIACIÓN DESARROLLO TECNOLÓGICO RURAL
Tax Identification Number (NIF): G02705176
Registered office: Calle Globo 28, Staircase 3, Ground Floor, Unit B, 50015 Zaragoza, Zaragoza, Spain.
Tax address and workplace: Calle Santa Bárbara 4, Staircase 1, 2nd Floor, Unit 1, 22728 Ansó, Huesca, Spain.
Telephone: +34 604 861 679
Email: fundacion@movimientotecnologicorural.org
Website: https://movimientotecnologicorural.org/
The Association acts as the data controller for personal data processing activities for which it determines the purposes and means of processing.
Data subjects may use the contact details above to submit privacy-related enquiries and exercise their data protection rights.
3. SCOPE OF APPLICATION
This Privacy Policy applies to personal data processing activities carried out by the Association through:
- The corporate website and its contact forms.
- Registration forms for activities, workshops and events.
- Membership and collaborator registration systems.
- Forms for participation in projects and initiatives.
- Subscriptions to newsletters and informational bulletins.
- Communications related to activities, projects and services.
- The blog and any associated participation features.
- Virtual tours developed using 3DVista Virtual Tour Pro.
- Statistical analytics tools, including Google Analytics 4.
- Integrations with external platforms such as YouTube, Vimeo and Google Maps, where applicable.
Virtual tours may be embedded in the corporate website or published through independent domains and subdomains under the Association’s responsibility.
Where an activity or project involves specific processing activities not sufficiently described in this policy, additional information will be provided to the individuals concerned.
4. PERSONAL DATA WE PROCESS
The Association may process the following categories of personal data, depending on the service used and the relationship with each individual.
4.1. Identification and contact information
- Full name.
- Email address.
- Telephone number.
- Organisation or entity represented.
- Professional position or role, where applicable.
- Information voluntarily provided through forms and communications.
4.2. Registration and participation data
- Identification and contact information.
- Requested activities, projects or events.
- Information required to manage registrations and applications.
- Information relating to participation in activities.
- Administrative information necessary to manage members, collaborators and projects.
Where an activity requires additional categories of personal data, specific information will be provided about their collection and processing.
4.3. Newsletter subscription data
- Email address.
- Full name, where provided.
- Date and method of subscription, where recorded.
- Communication preferences, where applicable.
- Information relating to consent and its withdrawal.
- Technical data necessary to manage communications.
4.4. Technical and browsing data
When using the website and virtual tours, the following data may be processed:
- IP address and technical connection information.
- Browser type, device and operating system.
- Date and time of access.
- Pages and resources requested.
- Information necessary for the operation and security of the services.
- Cookie identifiers, where applicable.
- Statistical information and browsing interactions, subject to consent where required.
The Association will endeavour to limit data collection to information that is adequate, relevant and necessary for each purpose.
5. PURPOSES AND LEGAL BASES FOR PROCESSING
Personal data will be processed for specified, explicit and legitimate purposes.
5.1. Contact forms
Purpose: to respond to enquiries, requests for information and communications received.
Legal basis: the Association’s legitimate interest in managing ordinary enquiries, pursuant to Article 6(1)(f) GDPR, where applicable; or taking steps at the request of the data subject prior to entering into a contract, pursuant to Article 6(1)(b), where appropriate.
Personal data will not automatically be used to subscribe individuals to the newsletter.
5.2. Registration for activities and events
Purpose: to manage applications, registrations, attendance confirmations, event organisation and communications directly related to the activity.
Legal basis: performance of a contract or taking steps at the request of the data subject, Article 6(1)(b) GDPR, where applicable; or consent, Article 6(1)(a), where this is the appropriate legal basis.
Registration for an activity does not automatically constitute acceptance of promotional communications unrelated to that activity.
5.3. Membership registration
Purpose: to process membership applications, manage admissions and withdrawals, maintain membership records and fulfil administrative obligations related to the Association.
Legal basis: Article 6(1)(b) GDPR for managing the membership relationship and Article 6(1)(c) for compliance with applicable legal obligations.
5.4. Collaborator registration
Purpose: to manage collaboration requests, establish professional relationships and coordinate joint initiatives.
Legal basis: performance of agreements or pre-contractual measures, Article 6(1)(b); duly justified legitimate interests, Article 6(1)(f); or consent, Article 6(1)(a), as applicable.
5.5. Participation in projects
Purpose: to manage participation requests, organise activities, coordinate participants, monitor progress and provide project reporting and justification.
Legal basis: the legal basis applicable to each project, which may include contractual performance, consent, compliance with legal obligations or legitimate interests, where applicable and duly justified.
Where a project requires specific processing activities, additional information will be provided before collecting the relevant data.
5.6. Newsletters and informational bulletins
Purpose: to manage subscriptions and send information about news, projects, activities, events, initiatives and updates from the Association.
Legal basis: consent of the data subject, pursuant to Article 6(1)(a) GDPR.
Data processed: email address and, where applicable, name, subscription date, preferences and information required to demonstrate consent.
Tools used:
The Association uses Google Workspace as its corporate environment for managing its newsletter.
Within this environment, it uses:
- Google Sheets: to store and organise subscription data.
- Google Apps Script: to implement automated processes related to subscription management and electronic communications.
These services enable the Association to operate its own newsletter management system without relying on a specialised third-party newsletter platform.
Data is processed through the Google services used by the Association, in accordance with the contractual and data protection terms applicable to those services.
Subscription is voluntary and is not required to access publicly available website content.
Each communication of this nature will include a simple and free-of-charge unsubscribe mechanism where required by applicable legislation.
Subscribers may also request removal from the mailing list by contacting:
fundacion@movimientotecnologicorural.org
Once an unsubscribe request has been processed, the data will no longer be used to send newsletters, without prejudice to the retention of the minimum information necessary to demonstrate compliance with legal obligations.
5.7. Communications with members, participants and collaborators
Purpose: to keep individuals associated with the Association informed about matters relating to their membership, participation in activities or involvement in projects.
Legal basis: performance of the relevant relationship, compliance with legal obligations or duly justified legitimate interests, depending on the circumstances.
Promotional communications requiring consent will be managed separately.
5.8. Website analytics
Purpose: to analyse visits, understand website usage and improve its content and services.
Tool: Google Analytics 4.
Legal basis: user consent, pursuant to Article 6(1)(a) GDPR, for the processing of personal data associated with analytics technologies requiring such authorisation.
Users may refuse or withdraw consent through the available privacy management mechanisms.
5.9. Operation and security of digital services
Purpose: to ensure the technical operation of the website and virtual tours, prevent unauthorised access, detect incidents and protect systems.
Legal basis: the Association’s legitimate interests under Article 6(1)(f) GDPR, where applicable and after considering the rights and freedoms of the individuals concerned.
Strictly necessary cookies are governed by the exemptions provided for in Article 22(2) of the LSSI-CE.
6. 3DVISTA VIRTUAL TOURS
The Association develops, manages and publishes interactive virtual tours using 3DVista Virtual Tour Pro.
These tours enable users to explore spaces through 360-degree panoramic photographs, images, videos, maps and multimedia elements.
Virtual tours may be embedded in the corporate website or published through independent web addresses.
6.1. Technical data
To enable virtual tours to function, technical information relating to connections, browsers, devices and access to multimedia resources may be processed.
Such processing will be limited to what is necessary to provide the service and ensure its security.
6.2. Google Analytics 4
Virtual tours may incorporate Google Analytics 4 to obtain statistical information about their use.
Depending on their configuration, statistical information may include:
- Number of visits.
- Scenes or panoramas viewed.
- Time spent on the tour.
- Type of device used.
- Approximate geographical origin.
- Interactions with navigation elements.
- Navigation sequences between content elements.
Where processing requires consent, analytics collection must comply with the preferences expressed by each visitor.
Refusal of analytics cookies must not prevent access to the essential features of the virtual tour.
Google Analytics 4 may process identifiers that constitute personal data, although Google does not store IP addresses in Analytics records.
6.3. Statistical reports
The Association may prepare aggregated statistical reports on virtual tour usage for clients, public administrations, partner organisations and other participating entities.
These reports may contain general information about visits, content viewed and user interactions.
Their purpose will not be to identify individual visitors.
6.4. Images and privacy
The Association will endeavour to avoid including recognisable individuals in panoramic photographs and audiovisual materials used in its virtual tours.
Where images that allow individuals to be identified are detected, appropriate measures will be adopted to protect their rights.
The capture and publication of identifiable images will comply with applicable data protection legislation and, where relevant, the right to one’s own image.
7. EXTERNAL SERVICES AND CONTENT
The corporate website and virtual tours may incorporate content and services managed by third parties.
7.1. YouTube and Vimeo
The Association may embed videos hosted on YouTube or Vimeo.
Loading or playing these materials may involve the disclosure of technical data to their providers, including connection information, device information and interactions.
Where consent is required for cookies or other non-essential technologies, the appropriate consent mechanisms will apply.
7.2. Google Maps
The website and virtual tours may incorporate Google Maps to display locations and geographical content.
Using this service may involve the processing of technical information by Google.
Where consent is required, the activation of the relevant technologies will comply with the user’s preferences.
The use of these external services may also be subject to their respective providers’ terms and privacy policies.
8. COOKIES
The Association uses technologies necessary for the operation of its digital services and analytics tools such as Google Analytics 4.
Non-essential cookies and technologies requiring consent will be managed through the appropriate information and consent mechanisms.
Visitors may accept, reject or configure these technologies and subsequently change their preferences.
Virtual tours published on independent domains must also provide the information and consent mechanisms appropriate to their configuration.
Detailed information about the cookies used, their purposes, providers, duration and management options will be available in the Association’s Cookie Policy.
9. SOURCE OF PERSONAL DATA
Personal data is primarily collected directly from data subjects when they:
- Complete forms.
- Register for activities and events.
- Apply to become members or collaborators.
- Participate in projects.
- Subscribe to the newsletter.
- Contact the Association.
- Use the website or digital services.
In certain activities, personal data may be received from partner organisations or participating entities, provided that an appropriate legal basis exists.
Where personal data is not obtained directly from the data subject, the information required under Article 14 GDPR will be provided, unless a statutory exception applies.
10. RECIPIENTS OF PERSONAL DATA
Personal data may be accessible to service providers whose involvement is necessary for the Association’s operations.
These may include:
- Web hosting and technical maintenance providers.
- Email service providers.
- Form management services.
- Statistical analytics tools.
- Audiovisual content and mapping platforms.
- Technology providers associated with virtual tours.
- Communication and newsletter management services.
10.1. Google Workspace
The Association uses Google Workspace, including Google Sheets and Google Apps Script, to manage electronic communications and subscriptions.
Google provides technological services to the Association and processes the relevant data in accordance with the contractual and data protection terms applicable to each service.
Where Google acts as a data processor, the obligations established under Article 28 GDPR will apply.
The Association will retain control over the purposes for which subscribers’ data is used and will endeavour to restrict access to authorised individuals.
10.2. Other recipients
Personal data may be disclosed to public administrations and competent authorities where required by law or supported by an appropriate legal basis.
Data may also be disclosed to partner organisations where necessary for activities or projects, provided that a valid legal basis exists and the relevant information has been provided to the individuals concerned.
The Association does not sell personal databases collected through its forms.
11. INTERNATIONAL DATA TRANSFERS
The use of external technology services, including certain Google services, may involve international transfers of personal data outside the European Economic Area.
Where such transfers occur, they must comply with the mechanisms established in Articles 44 and following of the GDPR.
Depending on the provider, service and destination country, safeguards may include:
- Adequacy decisions adopted by the European Commission.
- Standard Contractual Clauses approved by the European Commission.
- Other safeguards or mechanisms recognised under applicable legislation.
The Association must maintain up-to-date information about its service providers, any international transfers that actually take place and the safeguards applicable to them.
Data subjects may request information about international transfers affecting their personal data and how to obtain access to the relevant safeguards by contacting the Association.
12. DATA RETENTION PERIODS
Personal data will be retained for as long as necessary to fulfil the purposes for which it was collected and subsequently for any periods required by law or necessary to address potential liabilities.
The following criteria will apply, as appropriate:
Contact enquiries: for the duration of their management and any subsequent duly justified retention periods.
Activity registrations: throughout the organisation and delivery of activities and any applicable reporting or liability periods.
Membership records: throughout the membership relationship and any subsequent legally required periods.
Collaborator records: throughout the collaboration relationship and any applicable subsequent periods.
Project participation: throughout project implementation, monitoring, evaluation and reporting, including periods required by funding bodies or legislation.
Newsletter: until consent is withdrawn, the individual unsubscribes or another circumstance requires processing to cease, without prejudice to retaining the evidence necessary to demonstrate compliance.
Technical security data: for a proportionate period necessary to ensure security, investigate incidents and address liabilities.
Google Analytics 4: in accordance with the retention period configured in the tool and the characteristics of the data processed.
Anonymised statistical reports: for as long as they remain useful for their purposes, provided that they do not allow individuals to be identified.
Once the applicable retention periods have expired, personal data will be deleted, anonymised or subject to legally required restrictions on further processing, as appropriate.
13. DATA SUBJECT RIGHTS
Data subjects may exercise the rights recognised under applicable data protection legislation:
- Access: to know what personal data is being processed and obtain information about its use.
- Rectification: to request the correction of inaccurate or incomplete data.
- Erasure: to request the deletion of personal data where legally applicable.
- Objection: to object to certain processing activities.
- Restriction of processing: to request restrictions on processing in the circumstances established by law.
- Data portability: to receive certain personal data in a structured format and transmit it to another controller where applicable.
- Withdrawal of consent: to withdraw previously granted authorisations.
- Automated decision-making: to exercise the rights established under Article 22 GDPR.
To exercise these rights, individuals may contact:
ASOCIACIÓN DESARROLLO TECNOLÓGICO RURAL
fundacion@movimientotecnologicorural.org
The Association will generally respond within one month of receiving a request.
This period may be extended by a further two months where necessary due to the complexity or number of requests, provided that the individual is informed of the extension within the first month.
Where reasonable doubts exist concerning the identity of the applicant, proportionate additional information may be requested to verify their identity.
Exercising these rights is generally free of charge.
Data subjects may also lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos — AEPD):
14. SECURITY AND CONFIDENTIALITY
The Association will implement appropriate technical and organisational measures to protect personal data against loss, destruction, alteration, disclosure or unauthorised access.
These measures will be adapted to the nature of the information, existing risks and the characteristics of the systems used.
For data stored within Google Workspace, the Association must establish appropriate access, permission and administration controls.
Access to personal data will be limited to individuals and providers who legitimately need to process it.
Authorised individuals will be subject to the corresponding confidentiality obligations.
The Association will endeavour to apply the principles of data protection by design and by default.
15. PROCESSING OF MINORS’ PERSONAL DATA
Where the Association organises activities or projects involving minors, it will implement safeguards appropriate to their age and the nature of the processing.
In accordance with Article 7 of the LOPDGDD, where processing is based on consent, children under the age of 14 will generally require the consent of those exercising parental responsibility or legal guardianship, without prejudice to legally applicable exceptions.
Activities requiring additional authorisations will be subject to their specific conditions.
Minors’ personal data will not be used for purposes incompatible with those for which it was collected.
16. ELECTRONIC COMMUNICATIONS AND NEWSLETTERS
The Association may send newsletters, news and communications concerning its projects, activities and initiatives.
Voluntary subscriptions are managed through tools within the corporate Google Workspace environment.
The Association uses Google Sheets to organise subscriber information and Google Apps Script to automate processes related to subscription management and electronic communications.
Where consent is required for communications, it must be obtained through a freely given, specific, informed and affirmative action.
Registration for activities, submission of contact forms and membership applications do not automatically constitute subscription to the newsletter.
Recipients may request removal from the mailing list through the mechanisms provided in communications or by contacting the Association.
The Association may retain the minimum information necessary to demonstrate consent, its withdrawal and compliance with legal obligations.
17. PRIVACY INFORMATION IN FORMS
Contact forms, activity registrations, membership and collaborator applications, newsletter subscriptions and project participation forms must provide basic data protection information before submission.
This information will include, where applicable:
- Identity of the data controller.
- Purpose of processing.
- Legal basis.
- Recipients and international transfers, where applicable.
- Data subject rights.
- A link to this Privacy Policy.
Mandatory fields must be clearly identified and limited to the information necessary.
Where consent is required for a specific purpose, separate mechanisms will be used, without pre-ticked boxes.
Additional information will be available in this policy or in the specific privacy notices relating to each activity.
18. AUTOMATED DECISION-MAKING AND PROFILING
The Association does not use, in the ordinary processing activities described in this policy, solely automated decision-making systems intended to produce legal effects concerning users or similarly significantly affect them.
Website and virtual tour analytics are used to study browsing trends and improve services, rather than to make individual decisions of this nature.
The use of Google Apps Script to automate administrative processes or electronic communications does not necessarily constitute automated decision-making within the meaning of Article 22 GDPR.
If new processing activities requiring specific information about profiling or automated decision-making are introduced, the legally required information will be provided.
19. AMENDMENTS TO THIS PRIVACY POLICY
Asociación Desarrollo Tecnológico Rural may amend this Privacy Policy to reflect legislative changes, new activities, modifications to its digital services or updates to the technological tools it uses.
Where amendments significantly affect the processing of personal data, individuals will be informed through appropriate channels and renewed consent will be requested where legally required.
The current version will be available on the corporate website and may be accessed from virtual tours managed under the Association’s responsibility.
ASOCIACIÓN DESARROLLO TECNOLÓGICO RURAL
Last updated: 10 November 2026.